On April 16, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Evans, Aretha,
Evans, Tony, Sr.,
Perkins, Monique,
Tanksley, Faith,
Williams, Deon,
and
Choudhury , Mmarooful,
Diamond Staffing Services, Llc,
Hawthorn Suites Franchising, Inc.,
Jain , Sanjeev,
Noshahi, Mohammad Sadiq,
Tasacom Real Estate, Llc,
Tasacom Technologies Inc,
Wyndham Hotel Group, Llc,
Wyndham Hotels & Resorts, Inc.,
for OTHER PERSONAL INJURY
in the District Court of Dallas County.
Preview
FILED
10/10/2022 9:30 AM
FELICIA PITRE
DISTRICT CLERK
DALLAS CO., TEXAS
Martin Reyes DEPUTY
CAUSE NO. DC-21-04901
TONY EVANS SR., and ARETHA EVANS, IN THE DISTRICT COURT
§§§§§§§§§§§§§§§§§§§§
Individually and 0n behalf of their minor son,
T.E., deceased, FAITH TANKSLEY on behalf of
minor T.E., III, Individually and on behalf of
His father, T.E., deceased and
DEON WILLIAMS,
Plaintiffs,
v. 162ND JUDICIAL DISTRICT
TASACOM REAL ESTATE, LLC d/b/a
HAWTHORN SUITES DALLAS LOVE FIELD
HAWTHORN SUITES FRANCHISING, INC.,
WYNDHAM HOTELS & RESORTS, INC.,
MOHAMlVIAD SADIQ NOSHAHI,
DIAMOND STAFFING SERVICES, LLC, and
WYNDHAM HOTEL GROUP, LLC,
Defendants. DALLAS COUNTY, TEXAS
NOTICE OF REMOTE HEARING
NOTICE IS HEREBY GIVEN that a hearing will take place Via Zoom before the 162ml
District Court, Dallas County, Texas on December 12, 2022 at 1:00 p.m. The Zoom Link is on
the Court’s website (162nd Civil District Court (dallascountvorg) under JOIN VIRTUAL
COURTROOM. The following will be heard:
1. J
Defendant Sanjeev ain’s Motion to Dismiss Pursuant to Tex.R.CiV.P. 91A
173854v2
1 1
12777.002
Respectfully submitted,
THOMPSON, COE, COUSINS & IRONS, L.L.P.
By
Tasha L. Barnes
State Bar N0. 00796163
Eva DeLeon
State Bar No. 24074774
Morgan J. Wells
State Bar N0. 24106562
701 Brazos Suite 1500
Austin, Texas 78701
(512) 708-8200 — Telephone
(512) 708-8777 a Fax
tbarnes@thompsoncoe.com
edeleon@thompsoncoe.com
mwells@thompsoncoe.com
ATTORNEYS FOR DEF ENDANTS
TASASCOM REAL ESTATE, LLC D/B/A
HAWTHORN SUITES DALLAS LOVE FIELD,
MOHAMMAD SADIQ NOSHAHI AND
DIAMOND STAFFING SERVICES, LLC
173854v2
1 1
12777.002
CERTIFICATE OF SERVICE
By my signature above, I hereby certify that a true and correct copy of the foregoing has
been delivered on this the 10th day of October, 2022, to the following counsel of record Via e-
mail:
Nuru Witherspoon Jason Hopkins
Emily Taylor DLA PIPER LLP a} S)
The Witherspoon Law Group, PLLC 1900 N. Pearl St., Suite 2200
5565 Deer Creek, Unit A Dallas, Texas 75201
Dallas, Texas 75228 Jason.hopkins@dlapiper.com
witherspoon@twlglawyers.com
taylor@twlglawyers.com And
ATTORNEYS FOR PLAINTIFF
Christopher B. Donovan
DLA PIPER LLP (US)
1000 Louisiana Street, Suite 2800
Houston, Texas 77002
Christopherb.donovan(a)dlapiper.com
ATTORNEYS FOR DEFENDAN TS
HAWTHORN SUITES FRANCHISING,
INC. AND WYNDHAM HOTELS &
RESORTS, INC.
173854v2
1 1
12777.002
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: TASACOM REAL ESTATE, LLC
Name BarNumber Email TimestampSubmitted Status
Tasha LBarnes tbarnes@thompsoncoe.com 10/10/2022 9:30:47 AM SENT
Morgan Wells mwells@thompsoncoe.com 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: HAWTHORN SUITES FRANCHISING, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/10/2022 9:30:47 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/10/2022 9:30:47 AM SENT
Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: WYNDHAM HOTELS & RESORTS, INC.
Name BarNumber Email TimestampSubmitted Status
Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/10/2022 9:30:47 AM SENT
Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/10/2022 9:30:47 AM SENT
Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
RoseMarie Chambers rose.chambers@dlapiper.com 10/10/2022 9:30:47 AM SENT
Sally Jones sally.jones@dlapiper.com 10/10/2022 9:30:47 AM SENT
Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT
NURU WITHERSPOON witherspoon@twlglawyers.com 10/10/2022 9:30:47 AM SENT
sherry M.faulkner sherry.faulkner@us.dlapiper.com 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: MOHAMMADSADIQNOSHAHI
Name BarNumber Email TimestampSubmitted Status
Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT
Eva DeLeon edeleon@thompsoncoe.com 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: TONY EVANS
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT
Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: T. E.
Name BarNumber Email TimestampSubmitted Status
Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT
Automated Certificate of eService
This automated certificate of service was created by the efiling system. The filer served this
document via email generated by the efiling system on the date and to the persons listed below.
The rules governing certificates of service have not changed. Filers must still provide a certificate
of service that complies with all applicable rules.
Kiyomi Armistead on behalf of Eva DeLeon
Bar No. 24074774
KArmistead@thompsoncoe.com
Envelope ID: 69045883
Status as of 10/10/2022 10:36 AM CST
Associated Case Party: ARETHA EVANS
Name BarNumber Email TimestampSubmitted Status
Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT
Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT
Preview
FILED 10/10/2022 9:30 AM FELICIA PITRE DISTRICT CLERK DALLAS CO., TEXAS Martin Reyes DEPUTY CAUSE NO. DC-21-04901 TONY EVANS SR., and ARETHA EVANS, IN THE DISTRICT COURT §§§§§§§§§§§§§§§§§§§§ Individually and 0n behalf of their minor son, T.E., deceased, FAITH TANKSLEY on behalf of minor T.E., III, Individually and on behalf of His father, T.E., deceased and DEON WILLIAMS, Plaintiffs, v. 162ND JUDICIAL DISTRICT TASACOM REAL ESTATE, LLC d/b/a HAWTHORN SUITES DALLAS LOVE FIELD HAWTHORN SUITES FRANCHISING, INC., WYNDHAM HOTELS & RESORTS, INC., MOHAMlVIAD SADIQ NOSHAHI, DIAMOND STAFFING SERVICES, LLC, and WYNDHAM HOTEL GROUP, LLC, Defendants. DALLAS COUNTY, TEXAS NOTICE OF REMOTE HEARING NOTICE IS HEREBY GIVEN that a hearing will take place Via Zoom before the 162ml District Court, Dallas County, Texas on December 12, 2022 at 1:00 p.m. The Zoom Link is on the Court’s website (162nd Civil District Court (dallascountvorg) under JOIN VIRTUAL COURTROOM. The following will be heard: 1. J Defendant Sanjeev ain’s Motion to Dismiss Pursuant to Tex.R.CiV.P. 91A 173854v2 1 1 12777.002 Respectfully submitted, THOMPSON, COE, COUSINS & IRONS, L.L.P. By Tasha L. Barnes State Bar N0. 00796163 Eva DeLeon State Bar No. 24074774 Morgan J. Wells State Bar N0. 24106562 701 Brazos Suite 1500 Austin, Texas 78701 (512) 708-8200 — Telephone (512) 708-8777 a Fax tbarnes@thompsoncoe.com edeleon@thompsoncoe.com mwells@thompsoncoe.com ATTORNEYS FOR DEF ENDANTS TASASCOM REAL ESTATE, LLC D/B/A HAWTHORN SUITES DALLAS LOVE FIELD, MOHAMMAD SADIQ NOSHAHI AND DIAMOND STAFFING SERVICES, LLC 173854v2 1 1 12777.002 CERTIFICATE OF SERVICE By my signature above, I hereby certify that a true and correct copy of the foregoing has been delivered on this the 10th day of October, 2022, to the following counsel of record Via e- mail: Nuru Witherspoon Jason Hopkins Emily Taylor DLA PIPER LLP a} S) The Witherspoon Law Group, PLLC 1900 N. Pearl St., Suite 2200 5565 Deer Creek, Unit A Dallas, Texas 75201 Dallas, Texas 75228 Jason.hopkins@dlapiper.com witherspoon@twlglawyers.com taylor@twlglawyers.com And ATTORNEYS FOR PLAINTIFF Christopher B. Donovan DLA PIPER LLP (US) 1000 Louisiana Street, Suite 2800 Houston, Texas 77002 Christopherb.donovan(a)dlapiper.com ATTORNEYS FOR DEFENDAN TS HAWTHORN SUITES FRANCHISING, INC. AND WYNDHAM HOTELS & RESORTS, INC. 173854v2 1 1 12777.002 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: TASACOM REAL ESTATE, LLC Name BarNumber Email TimestampSubmitted Status Tasha LBarnes tbarnes@thompsoncoe.com 10/10/2022 9:30:47 AM SENT Morgan Wells mwells@thompsoncoe.com 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: HAWTHORN SUITES FRANCHISING, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/10/2022 9:30:47 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/10/2022 9:30:47 AM SENT Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: WYNDHAM HOTELS & RESORTS, INC. Name BarNumber Email TimestampSubmitted Status Christopher BDonovan Christopher.B.Donovan@dlapiper.com 10/10/2022 9:30:47 AM SENT Jason Hopkins 24059969 jason.hopkins@dlapiper.com 10/10/2022 9:30:47 AM SENT Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status RoseMarie Chambers rose.chambers@dlapiper.com 10/10/2022 9:30:47 AM SENT Sally Jones sally.jones@dlapiper.com 10/10/2022 9:30:47 AM SENT Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT NURU WITHERSPOON witherspoon@twlglawyers.com 10/10/2022 9:30:47 AM SENT sherry M.faulkner sherry.faulkner@us.dlapiper.com 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: MOHAMMADSADIQNOSHAHI Name BarNumber Email TimestampSubmitted Status Ronald DHinds rdhinds@verizon.net 10/10/2022 9:30:47 AM SENT Eva DeLeon edeleon@thompsoncoe.com 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: TONY EVANS Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: T. E. Name BarNumber Email TimestampSubmitted Status Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Kiyomi Armistead on behalf of Eva DeLeon Bar No. 24074774 KArmistead@thompsoncoe.com Envelope ID: 69045883 Status as of 10/10/2022 10:36 AM CST Associated Case Party: ARETHA EVANS Name BarNumber Email TimestampSubmitted Status Aubrey "Nick" Pittman pittman@thepittmanlawfirm.com 10/10/2022 9:30:47 AM SENT Emily Taylor taylor@twlglawyers.com 10/10/2022 9:30:47 AM SENT Nuru Witherspoon litigation@twlglawyers.com 10/10/2022 9:30:47 AM SENT